The record
On September 25, 2024, the Federal Trade Commission announced a proposed settlement with DoNotPay, Inc., resolving a complaint alleging the company's marketing overstated what its subscription service could do. The complaint describes DoNotPay advertising itself as “the world's first robot lawyer,” capable through a chatbot of drafting “ironclad” demand letters, contracts, and small-claims filings, applying relevant law to a subscriber's specific facts, and detecting legal violations on a small-business website from nothing more than an email address. The FTC alleges the service did not, in fact, operate like a human lawyer in these respects, and that some advertised features, including a copyright-protection and cease-and-desist generator included in the general membership, were not available at all. The Commission finalized the order on January 17, 2025, and its own case page states the settlement requires DoNotPay to pay $193,000 and notify subscribers who used the service's law-related features between 2021 and 2023.
What the documents establish
The complaint sets out two counts under Section 5 of the FTC Act: false or unsubstantiated performance claims about the AI's ability to function like a lawyer, and separately, false claims about the website-scanning feature and about legal-document features included in a general membership. The decision and order requires the $193,000 payment, a notice to affected subscribers in a specified form, and prohibits DoNotPay from representing that any covered product or service can substitute for a professional service, such as legal advice, without competent and reliable evidence. The complaint separately recounts that the California State Bar investigated the service for the unauthorized practice of law beginning in November 2021, and that DoNotPay told the Bar it would drop the “robot lawyer” language, then continued using it — a fact the FTC's own complaint records, distinct from any finding a court has made about unauthorized practice of law.
The operating read
Editorially, the order targets a specific marketing pattern: describing an AI product's capability in terms borrowed from a licensed profession — lawyer, ironclad, detects violations — without evidence the product performs those functions the way the words imply. The order's forward-looking prohibition on unsubstantiated substitute-for-a-professional-service claims reaches beyond DoNotPay's own future conduct only in the sense that it signals what the FTC treats as actionable in this category generally.
What to check before you decide
Before adopting similar language for an AI-enabled product, check the following:
- Can each specific capability claimed in marketing, not just the product's general theme, be substantiated with evidence available before the claim is made?
- Do professional-sounding terms, such as lawyer, advisor, or certified, imply a credential or process the product does not actually have?
- Are all advertised features, including ancillary ones bundled into a subscription tier, actually available to the subscribers being sold that tier?
This describes the FTC's own complaint and order; it is not a finding about any other company's AI-enabled product.
Sources & their limits
These are the existing record’s sources and retrieval dates, preserved from the archive. Source statements, historical events and editorial interpretation are distinct.
- In the Matter of DoNotPay, Inc., Complaint, Docket No. 2323042
Sets out the FTC's specific allegations about DoNotPay's robot-lawyer marketing and unavailable advertised features.
- In the Matter of DoNotPay, Inc., Decision and Order
States the $193,000 payment, subscriber-notice requirement, and prohibition on unsubstantiated substitute-for-professional-service claims.
- DoNotPay (FTC case summary page)
FTC's own case summary and timeline confirming the September 2024 proposed order and January 2025 finalization.